EY ITS Washington Dispatch, May 2020

06/04/20 • 18 min

The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: Congress considers further action to address coronavirus pandemic – IRS finalizes proposed Section 385 regulations with no substantive changes, leaves distribution rules in effect – Treasury and IRS announce references to NAFTA in US tax treaties should be interpreted as references to USMCA – IRS offers limited relief for filing Forms 8858 or 8865 – IRS announces modifications for filing APA and MAP requests, addresses pending and executed APAs – New refocusing on BEPS, OECD official says – OECD holds public consultation on 2020 review of CbCR – OECD hosts webcast offering update on tax work during COVID-19 crisis; July IF meeting delayed to October 2020.

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EY ITS Washington Dispatch, April 2020

The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: President Trump signs interim coronavirus relief measure; attention turns to COV’ID-19 bill #4 – IRS issues final and proposed regulations on hybrid mismatches, DCLs and conduit financing – IRS regulations include new anti-abuse rule targeting certain ‘GILTI gap period’ transactions – Taxpayers need to consider international tax implications of making certain NOL elections under Rev. Proc. 2020-24 – IRS issues FAQs on interaction of NOL carrybacks and Section 965 inclusions – IRS announces taxpayers can temporarily fax Forms 1139 and 1045 to claim NOL carrybacks and AMT credits under CARES Act – IRS provides relief for potential tax consequences caused by COVID-19 travel restrictions – IRS withdraws 2004 Notice on ‘Midco’ transactions – IRS releases FAQs on transfer pricing documentation best practices – IRS issues annual APA report for 2019 – IRS updates FATCA FAQs – OECD BEPS 2.0 project to continue on current timelines – OECD issues guidance on impact of the COVID-19 crisis on treaty-related issues – OECD releases second batch of Stage 2 peer review reports on dispute resolution.

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EY ITS Washington Dispatch, June 2020

The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US Supreme Court declines to hear Altera case – US Treasury Secretary calls for ‘pause’ in BEPS 2.0 Pillar 1 discussions – USTR initiates investigations into implemented / proposed DSTs in 10 jurisdictions – IRS LB&I official offers insights to TCJA compliance campaign – IRS seeks 2020-2021 Priority Guidance Plan recommendations – OECD releases toolkit on taxation of offshore indirect transfers of assets – OECD circulates COVID-19 transfer pricing survey to BIAC members.